Special statute trial procedure limits habeas corpus relief in TADA cases, even where speedy trial concerns are raised.

A habeas corpus petition was treated as unavailable to secure release of an undertrial in a TADA prosecution where the complaints concerned remand, adjournments, and trial delay. The special statute was regarded as a self-contained code for proceedings before the Designated Court, with the CrPC applying only to the extent permitted by the Act. Those grievances were to be pursued before the Designated Court and, where appropriate, through the statute's appellate route to the Supreme Court. Article 21's right to speedy trial was recognised, but it did not by itself justify automatic release or displace the special statutory forum absent clear illegality.

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Issues: Whether a habeas corpus petition could be entertained to secure release of an undertrial detained under the Terrorist and Disruptive Activities (Prevention) Act, 1985 on the grounds of alleged illegal remand, repeated adjournments, and infringement of the right to speedy trial under Article 21 of the Constitution of India.

Analysis: The statutory scheme of the Terrorist and Disruptive Activities (Prevention) Act, 1985, especially Section 12(4) and Section 16, was treated as a self-contained code for trial before the Designated Court, with the procedure of the Code of Criminal Procedure, 1973 operating only to the extent permitted by that Act. The Court held that the complained-of defects in adjournment and remand, even if raised, were questions to be pursued before the Designated Court, and any challenge to bail or trial management had to follow the special statutory route to the Supreme Court. The right to speedy trial under Article 21 was recognised, but it was not treated as an automatic ground for release in a pending TADA trial where the accused had an effective forum available and the record did not justify habeas corpus interference by the High Court.

Conclusion: The petition was not maintainable for the relief sought before the High Court and the detention was not held illegal on the asserted grounds.

Ratio Decidendi: Where a special statute provides a self-contained trial and appellate mechanism and the grievance concerns remand, adjournment, or bail in a pending special-statute trial, the High Court will not grant habeas corpus relief unless a clear illegality is shown, and the right to speedy trial under Article 21 does not by itself displace the statutory forum or justify automatic release.

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